A. Description of the Advisory Firm VanderPol Investments LLC (hereinafter “VPI”) is a Limited Liability Company organized in the State of Michigan. The firm was formed in May 2013, and the principal owner is Mark A. VanderPol. B. Types of Advisory Services VPI is a registered investment adviser in the state of Michigan. We provide investment advisory services to individuals, and high net worth individuals concerning various securities including equities, fixed income, and derivatives. As a registered investment adviser, we are held to the highest standard of client care - a fiduciary standard. As a fiduciary we always put our client's interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities and all transactions are sent to our qualified custodian which executes, compares, allocates, clears, and settles them. Our custodian also maintains our clients' accounts and may grant clients access to them. We accept and enter trades on both a discretionary and a non- discretionary basis. VPI offers the following services to advisory clients: Portfolio Management VPI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. This service may include financial planning, tax planning or other unrelated consulting for those clients that desire extra service. VPI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). VPI can review all financial issues for our clientele, allowing for a balanced approach towards investments and risks in life. We will consider any additional insurance they may need, and the most appropriate investment strategy to achieve any and all of their goals. Portfolio management services include, but are not limited to, the following:
• Customized Portfolio Management
• Automatic Rebalancing
• Periodic Reviews and Adjustments
• Access to a Broad Range of Investments
• Transparent Reporting and Communication
• Educational Resources and Support For clients who maintain assets of more than $250,000 in management with VPI will also receive:
• Tax Optimization Strategies
• Estate Planning
• Charitable Gift Planning
• Insurance Planning
• Tax Planning VPI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. VPI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VPI’s economic, investment or other financial interests. To meet its fiduciary obligations, VPI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, VPI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VPI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Model Portfolios VPI maintains twelve model portfolios that range from high risk to low risk that are implemented in a variety of ways depending on cost effectiveness, client tax situations, and successful execution of strategy. These portfolios may be made up of ETFs, mutuals funds, individual stocks and or individual bonds. VPI emphasizes a Pastor-Stambaugh Model within each of these model portfolios that emphasizes small-capital weighted, value-oriented, illiquid equities relative to an appropriate benchmark. VPI considers the global equities benchmark of MSCI ACWI USD NR to be an appropriate measure of its equity’s exposure and the Barclays US Aggregate Bond index an appropriate measure of its fixed income exposure and provides performance reports against these benchmarks to individual accounts based on the current percentage of equities held in the account rounded to the nearest ten percent and the remainder measured against the fixed income benchmark. In our most basic models, VPI utilizes only low-cost ETFs that are highly diversified and are our favorite selection within their asset class. Going another step further, VPI may allocate those securities differently across Roth IRAs compared to traditional IRAs or taxable accounts in order to

potentially generate higher after-tax returns. With more scale, VPI may find it more beneficial to incur a small custodial transaction fee for more precise implementation of the overall strategy and utilize mutual funds with large factor tilts in conjunction with extremely low-cost index ETFs. When accounts are large enough for effective implementation, VPI may use a stratified sampling direct-indexing technique to provide optimal tax loss harvesting or donation options within the large cap US equities and or international equities allocations. Finally, VPI may utilize alternative investments (private equity funds, private real estate funds, private credit funds, hedge funds) to hopefully earn the illiquidity premium illustrated within the Pastor-Stambaugh model. Financial Consulting Services VPI provides financial consulting services to the Client on an hourly or retainer basis. Services shall include, but not be limited to, personal budgeting advice, evaluations of capital expenditure opportunities within their business, and other finance-related consulting services as requested by the Client. The exact nature of the services to be provided will be determined on a case-by-case basis, allowing for a broad interpretation of the financial consultancy remit. Pension Consulting Services VanderPol Investments offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Pension consulting services may involve the direct investment management of one or more 401(k) participant accounts, provide the selection and monitoring process for the various mutual funds offered to plan participants, develop and maintain an Investment Policy Statement for the plan, and/or provide group and individual employee education on investment options, asset allocation, and retirement planning. Participant Account Management (Discretionary) VPI uses a third party platform, Pontera, to facilitate management of atypical accounts, such as current 401k’s and other defined contribution plan participant accounts, with discretion. The platform allows VPI to avoid having custody of client funds since VPI does not have direct access to client log-in credentials to affect trades. VPI is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, VPI will review the current account allocations. When deemed necessary, VPI will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. VPI may also provide its clients newsletters for no additional charge. Services Limited to Specific Types of Investments VPI generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), non-U.S. securities, hedge funds, private equity funds, private credit funds, venture capital funds, and insurance products, including annuities. C. Client Tailored Services and Client Imposed Restrictions VPI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels), and cost efficient implementation for its clients. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent VPI from properly servicing the client account, or if the restrictions would require VPI to deviate from its standard suite of services, VPI reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. VPI does not participate in any wrap fee programs. E. Assets Under Management VPI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 123,126,425 $0.00 December 2023